The Delhi High Court ruled that a deceased found crying alone cannot prove dowry harassment, upholding dismissal of 498A charges against the husband and in-laws.
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NEW DELHI: The Delhi High Court has once again clarified the scope of Section 498A of the Indian Penal Code (IPC), ruling that vague allegations and emotional assumptions cannot be the basis for criminal prosecution. Justice Neena Bansal Krishna, while dismissing a petition, upheld the discharge of a husband and his family from charges of cruelty and dowry harassment.
Background of the Case
The case arose from allegations that a woman, married in December 2010, faced harassment and dowry demands from her husband and in-laws. Her family claimed to have spent nearly Rs 4 lakh on the wedding, after which demands were allegedly made for a motorcycle, cash, and a gold bracelet. The woman, a mother of two daughters, tragically passed away on 31 March 2014.
An FIR was registered in April 2014 under Sections 304B/498A/34 IPC. While the Additional Sessions Judge discharged the accused under Section 304B (dowry death), citing medical reports that attributed her death to pneumonia, a natural cause, the case was sent for trial under Sections 498A/34 IPC. Later, in June 2016, the Metropolitan Magistrate discharged the accused under these provisions as well, pointing out the lack of specific evidence. This order was upheld in April 2017.
Arguments by the Parties
Petitioner:
The petitioner contended that:
- At the stage of framing charges, only prosecution material should be considered.
- Statements under Sections 161 and 164 Cr.P.C. recorded allegations of harassment and dowry demands.
- Medical details like frothing from the mouth and semi-solid stomach contents were ignored.
- Even if death was from pneumonia, the family failed to provide adequate treatment.
It was argued that courts below overlooked specific allegations and binding precedents requiring charges to be framed when prima facie material is available.
Respondent:
The respondents denied all allegations, terming the petition time-barred and motivated by ulterior purposes.
High Court’s Analysis
Justice Neena Bansal Krishna examined the scope of Section 498A IPC, which requires:
- Clause (a): Wilful conduct likely to drive a woman to suicide or cause grave injury, or
- Clause (b): Harassment to coerce her or her family to meet unlawful dowry demands.
Since medical records confirmed death due to pneumonia, Clause (a) was held inapplicable. On Clause (b), the Court found the allegations to be general, contradictory, and without specific incidents or dates. The Court also observed,
“Merely because the deceased was crying, cannot per se make out any case of dowry harassment.”
Statements from her siblings that they saw her crying on Holi did not establish harassment for dowry. Additionally, customary gifts like Chuchak could not be equated with dowry demands.
The Court cited several rulings to support its reasoning:
- Jayedeepsinh Pravinsinh Chavda v. State of Gujarat (2025) 2 SCC 116
- Dara Lakshmi Narayana v. State of Telangana (2024)
- Digambar Case
These judgments emphasized that vague and omnibus allegations without specific details cannot constitute cruelty under Section 498A IPC.
The Court concluded that no prima facie case was made out and dismissed the petition.
“There is no merit in the present Petition, which is hereby dismissed.”
Click Here to Read More Reports On Section 498A IPC
